2026 Retrofit Guide for Legacy, Used, and Imported Machine Guarding

Frequently Asked Questions

Does OSHA allow employees to use older machines without OEM guards?

No. If employees use the machine, the employer is responsible for controlling the hazard, even when OEM guards are missing or the equipment is old.

Are imported machines automatically compliant if they were built for another market?

No. Imported equipment still has to be evaluated against applicable OSHA machine-guarding requirements before use in your facility.

What should a used equipment hazard audit cover?

It should review normal production, setup, changeover, jam clearing, cleaning, maintenance, and all relevant energy sources. The goal is to find where employees are exposed during real tasks, not just inspect the machine visually.

What is the best first step before retrofitting old machinery guards?

Start with a task-based hazard review. Breaking down each job step helps identify the real exposure points and choose controls that fit the machine and the work.

What documentation should be kept after a machine-guarding retrofit?

Keep the machine description, pre-retrofit photos, hazard findings, control decisions, retrofit details, procedure updates, training records, and post-installation verification.